OIG Focuses on the Next Generation of CIAs

HHS, Office of Inspector General (OIG) held a roundtable meeting with company representatives in August 2012, and recently published a paper, Focus on Compliance: The Next Generation of Corporate Integrity Agreements, summarizing that discussion. The paper highlights the roundtable discussions and provides guidance to companies that are currently negotiating corporate integrity agreements (CIAs).

The paper summarizes each of the most common requirements of a CIA including: a) the definitions of “covered persons” and “relevant covered persons;” b) codes of conduct, compliance policies and procedures, and training and education; c) the role of the compliance officer, internal auditing and audit plans, and the role of the board of directors; d) claims review requirements; and d) arrangements review requirements.

The paper also offers a number of potential negotiation points for companies that are involved in CIA negotiations. To obtain a copy of the entire OIG roundtable meeting paper click here.